SGS MA_Final_Part3.pdf

Commonwealth of Massachusetts

Vehicle Inspection and Maintenance Program

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Technical Response 5-174 April 7, 2016

The SGS Auditors report directly to the MAC Manager for duty assignments. However, these

Auditors also have a reporting obligation to our Program QA Manager to inform the SGS quality group about the results and trends arising from their auditing operations. This arrangement further allows SGS to maximize our use of MAC auditing personnel while ensuring QA oversight for the auditing functions they perform.

Due to their interaction with motorists, SGS provides basic customer service training to SGS

RRTs and Auditors so that each can handle interactions with motorists in a professional manner.

Covert Vehicle Fleet [3.2.1.9.A.2, 6.9] 5.9.2

To complete the required covert vehicle audits, SGS determined that one vehicle per each of the ten MACs (i.e., a total of ten vehicles) is sufficient to perform at least 900 audits annually, including the capability to perform Agency-driven audits. Perhaps the most important feature of each purchased vehicle is that it is as “typical” as possible to maintain low visibility within the inspection community. That is, no new vehicles will be purchased and a variety of domestic and foreign brands is preferred. Also, we will sell and replace these vehicles approximately every nine months to maintain “fresh” auditing subjects.

While the likelihood that any given Inspector might recognize a given vehicle is low, SGS wants to ensure that we maintain the validity of a true, unbiased auditing process throughout the

Program. Therefore, to discourage accidental discovery of audit vehicles, SGS will implement the following procedures:

Source vehicles from a variety of dealers across the Commonwealth

Use audit vehicles only for audits, not other functions within the MAC (e.g., delivery of spare parts to an Inspection Station)

Cover vehicles when not in use

Cease using and immediately replace any vehicle suspected of being compromised

Perform covert vehicle audits at least 10 miles from its host MAC location

Provide sufficient variety of vehicles to audit different Inspection Station license classes

(e.g., Non-Commercial, Commercial, 7D, Motorcycle)

Communicating Covert Inspection Results to Agency Staff [3.2.1.9.A.3, 6.9.3] 5.9.3

The results of all covert audits are immediately posted to the VID after completion and available to authorized users via SMART. SMART allows the Agencies to immediately access

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Technical Response 5-175 April 7, 2016 this data and provides customized selection of information and viewing options (i.e., view directly, download, sort/extract, or print). A link to the video associated with a specific visual audit is available within one business day. Failed audits trigger SMART notifications to the user for immediate attention, and these notifications are also available within one day of the inspection.

Of particular importance to the Agencies is having sufficient covert audit information available to meet EPA reporting requirements under 40 Code of Federal Regulations (CFR) 51.366, Appendix V – Criteria for Determining the Completeness of Plan Submissions. All covert audit data is stored on the VID (separate from “normal” inspection data, as described in Section 5.9.6) and is available to authorized Agencies’ personnel to complete EPA reporting requirements.

Covert Inspection Video [3.2.1.9.A.4, 6.9] 5.9.4

Because of the size of required video data files to substantiate covert visual audits, it is not practical to submit these files by email with the failed audit notification. However, the failed audit notification has a link to the video for immediate access and downloading via the SMART.

Video is time-stamped with the unique Inspection Station identifier number for ease of retrieval and verification of the correct video being accessed.

Conversion Factors [3.2.1.9.A.5, 6.9] 5.9.5

SGS has determined a conversion factor for “trading” covert vehicle audits for covert visual audits (or vice versa) should the Agencies adjust the relative number of one or the other audit type in the future. The basis of our conversion is the following:

Visual audits require one-half hour per audit (Sect. 5.9.1)

Vehicle audits require three hours per audit (Sect. 5.9.1)

Therefore, SGS Auditors can perform six times as many visual audits as vehicle audits per hour. As a result, for every reduction of 100 visual audits (for example), SGS will perform an additional 100/6 = 17 vehicle audits. Similarly, for every reduction of 10 vehicle audits (again, for example), SGS will perform 10 x 6 = 60 additional visual audits.

Integrating Covert Audit Reporting into the Database [3.2.1.9.A.6, 6.9] 5.9.6

To be effective, the covert vehicle audit must exactly mimic a “normal” safety/emissions inspection throughout the inspection process. The Workstation must see and read the vehicle as being typical with normal identifying features (e.g., appropriate VIN), with only the pre-set fail

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Technical Response 5-176 April 7, 2016 feature(s) triggering a failed VIR for that particular (audit) inspection. Normal readings are taken, actual inspection results are transmitted to the VID through the Workstation, a VIR is printed, and if the vehicle passes the inspection—whether intended or not—a vehicle inspection sticker is applied to the vehicle.

All covert audit data is stored on the VID, but in separate tables from regular vehicles and inspections. SGS has performed this covert audit VID function successfully for the last eight years for the Agencies. The separate data tables allow a clear separation between regular inspection data and covert inspection data and ensures controlled access of the covert data no matter the means (e.g., management console reporting). Upon the start of an inspection test, and while keeping the Inspector unaware of the process, the VID compares the vehicle to a list of known covert vehicles. If the vehicle is identified as covert, all interactions for the vehicle and inspection history occur with the covert data tables, rather than the standard vehicle tables. This provides an identical vehicle interaction with the Workstation and gives the appearance of a standard inspection while storing the inspection data securely for later auditing.

For covert visual audits, the Inspection Station is unaware of image and video data being accessed during the audit (which occurs the day after the inspection). Therefore, no re-routing of video/image data streams or risk of incidental/unplanned notification of audit activity occurs for visual audits.

Covert Audit Start-up Schedule [3.2.1.9.A.7, 6.9] 5.9.7

SGS’s schedule for beginning covert vehicle and visual audit operations is summarized in

Figure 5.9-4. The longest duration task that must be completed for implementation of our covert audit functions is scouting, leasing, and then building out our ten

MACs. As discussed in Section 5.11, SGS is pro-actively selecting MAC locations that are most beneficial to the motorist, and not merely inexpensive or readily available.

Figure 5.9-4: Covert Audit Implementation Schedule.

SGS begins covert auditing tasks within program schedule.

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Technical Response 5-177 April 7, 2016

We expect the procurement and build-out of the MACs to occur from September 2016

(contract award) through October 2017. As MACs become available, SGS immediately moves in and initiates normal MAC functions, including “hosting” of its designated covert vehicle. When the final MAC is ready for occupancy by October 2017, SGS completes its final covert vehicle purchase.

SGS plans to complete hiring and training of our internal SGS RRTs by early July, 2017 and will conduct Auditor training during September 2017 to begin covert visual auditing no later than

October 1, 2017. SGS will begin covert vehicle auditing on January 2, 2018 to allow the MACs and other implementation items to settle into routine tasks and allow prioritization of other implementation tasks before covert vehicle auditing begins. SGS will complete the required 900 covert vehicle audits for the first Program year within the remaining nine months.

SGS also provides training to the Agencies’ staff at least once per year on accessing and using audit data obtained during the covert audit process. The primary tool for the Agencies to access data from the VID and customize their reporting and querying capability is through SMART.

SGS will demonstrate how the covert audit data is accessed from the VID, including a full camera/video review for both a typical visual and a typical vehicle audit. We will present the multiple capabilities available to the Agencies from SMART that are specific to the covert auditing effort. We can perform this covert auditing and SMART training at the Agencies’ facilities or present a class at the Quincy MAC located closest to the Agencies’ offices.

5.10 VEHICLE MAINTENANCE INITIATIVE (VMI) [3.2.1.10, 6.10]

The Massachusetts Vehicle Maintenance Initiative (VMI) is a cornerstone of the Program’s core goals:

Pollution Reduction. The VMI promotes pollution reduction by providing prospective and active Registered Emissions Repair Technicians (Registered Repairers) and

Registered Repair Facilities (RRFs) with the tools and support they need to supply effective, high-quality emissions repairs to the Commonwealth of Massachusetts.

Safe Motor Vehicles. Becoming a Registered Repairer requires several training courses, including general mechanical and advanced engine performance coursework, leading to a better qualified automotive professional who diagnoses emissions repair issues and ensures overall vehicle safety.

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Technical Response 5-178 April 7, 2016

Motorist Convenience. SGS uses our MACs to provide zero-cost emissions diagnostics for vehicles failing their annual inspection, allowing motorists to speak to a highly-qualified MAC Registered Repairer for “next step” options. We also provide motorists with an information jacket for a (failed) VIR that provides helpful information on: their next steps, the nearest MAC, nearby and highest-rated RRFs, and why their vehicle failed inspection.

Fitting In with the Automotive Industry. SGS will work closely with the Agencies’ committee of automotive repair industry stakeholders (e.g., Inspection and Maintenance

Program Advisory Council [IMPAC] and their associated members) to identify opportunities to reach out to skilled Repair Technicians and facilities, especially in under-represented areas, to encourage advancement to Registered Repairer and RRF status. We will demonstrate the benefits of being in the Program, and encourage and motivate them to take that extra step.

How SGS will meet these Program core goals and provide for VMI growth in the new

Program is summarized in Figure 5.10-1 and described in the sections that follow.

Figure 5.10-1: VMI Growth Results from Many Contributors. SGS’s Inter-Related VMI Plan Ensures Maximum

Program Benefits.

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Technical Response 5-179 April 7, 2016

Figure 5.10-2 presents the features of our VMI solution (RFR 6.10) that increase the likelihood of Program success and produce tangible benefits to the Agencies and affected stakeholders.

Figure 5.10-2 Best Value Features of SGS’s Proposal. Our VMI maximizes effectiveness through coordinated SGS contributions.

Strength (Feature of SGS Offer that Increases

Likelihood of Successful Performance or Exceeds

Capability Requirements)

Tangible Benefits to the Commonwealth, Inspectors, RRTs, and/or Motorists

Criteria 4: Program Support Elements

All ten MACs available for training courses – as opposed to only 5 currently used for training purposes.

Is Convenient for Repairers: Greater accessibility for both prospective and existing Inspector students encourages continued learning.

Targeted, focused outreach to encourage both new and current Repair Technicians to become Registered Repairers;

repair choice data collected at Inspection Station

Improves Air Quality and Vehicle Safety: Targeted recruitment of new RRFs based on regional usage data collected at Inspection Stations.

Exploring use of applying VID information to automatically generate Emissions Repair Success Rating

(ERSR) instead of relying solely on repair facility to enter data

Attractive Business Opportunities: Enable more repair stations to achieve a 5-star rating through improved data management.

VMI Vision and Plans [3.2.1.10.A, 6.10] 5.10.1

Since its inception in 2008, the VMI has not performed to its full potential under the direction of the current contractor, having graduated just over 400 Registered Repairers and with only 188

RRFs through 2015 (out of 5,000+ eligible inspectors/technicians and almost 2,000 inspection/repair facilities, respectively). Specifically, the number of Program RRFs has steadily declined over the last five years: 2011-303, 2012-274, 2013-223, 2014-216, and 2015-188.

Therefore, SGS sees great opportunity in improving the VMI function throughout the

Commonwealth through focused outreach to skilled technicians and emissions repair facilities, high-quality and accessible training that emphasizes career advancement, and working closely with industry leaders to promote VMI programs.

The SGS vision for the Massachusetts VMI is: By actively and directly encouraging automotive technicians within targeted “high need” areas to become Registered Repairers – leading to greater numbers of high quality and better located Registered Repair Facilities – the community, motorist, repair industry, and Massachusetts air quality ALL benefit.

Figure 5.10-3 illustrates how our vision assists the automotive repairers, repair facilities, and the general public in meeting Massachusetts’ air quality goals through the VMI.

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Technical Response 5-180 April 7, 2016

Figure 5.10-3: State Air Quality Directly Benefits from VMI Improvement. Increased Registered Repairers and

RRFs benefits all.

SGS’s initial step after contract award is to prepare our VMI Plan and submit it to the

Agencies for review and approval. This plan will discuss our outreach strategy for increasing

Registered Repairer and RRFs in targeted, under-represented areas of the Commonwealth

(presented in greater detail in Section 5.10.5).

The requirements to become a Massachusetts Registered Repairer are:

Current Automotive Service Excellence (ASE) Advanced Engine Performance Specialist

Certification (L-1). This certification requires as a pre-requisite an ASE Engine

Performance Certification (A8), with ASE Light Vehicle Diesel Engines Certification

(A9) required for work on diesel engines.

Successful completion of the four Mass Module training modules: 1) Vehicle Inspection

Requirements; 2) Registered Emissions Repair Technician and Repair Shop

Requirements; 3) Motorist Assistance Resources; and 4) Vehicle Emissions Inspection and Diagnostic Repair. A total of 25 separate Massachusetts Program-specific training subjects are included in the four on-line training modules making up the Mass Module, which can be taken via computer-based training (CBT) for student convenience. Each module is reviewed separately followed by an on-line examination.

Successful completion of the Supplemental OBD Repair Training Course. This 28-hour course provides hands-on and classroom training for OBD diagnosis and repairs and will be updated and modernized throughout the life of the Program. Further details of this course are provided in Section 5.10.2.

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Technical Response 5-181 April 7, 2016

Successfully complete an annual OBD-related training course to maintain an up-to-date knowledge base for this important emissions testing component. This training is offered quarterly and will be classroom-based using specialist trainers such as Mr. Chuck Gee

(Section 5.7.1.2), and Messrs. Chuck Pearson, David Protano, Gary Machiros, and Craig

Blake from Automotive Training Group (ATG).

For a new Repair Technician, becoming a Registered Repairer is neither easy nor easily accessible. The ASE L-1 test is comprehensive over all engine systems and requires three years’ experience before taking the L-1 test. Therefore, becoming a Registered Repairer requires a commitment of time and energy from the new Technician that starts well before Mass Module, Supplemental OBD, or Annual OBD refresher training occur. Conversely, for Repair

Technicians who already have their L-1 Certifications, becoming a Registered Repairer is very simple and straight-forward. They just have to complete the Mass Module, Supplemental OBD, and Annual OBD-refresher training and complete the on-line registration process.

Therefore, a key performance issue for the current VMI appears to be a lack of outreach and encouragement to this group of available, experienced automotive professionals ready to contribute to the Program. By increasing the number of Registered Repairers more quickly in this way, additional RRFs are created and prospective new technicians see tangible benefits growing before them through the VMI. Given this need to more aggressively encourage the VMI core groups (Registered Repairers and RRFs), our plan to maximize the addition of new

Registered Repairers and RRFs is two-fold:

1) Determine in a focused, analytical approach what areas of the Commonwealth are most in need of RRFs (which require Registered Repairers) to better meet motorist demands for high-quality emissions repairs in under-represented areas.

2) Apply SGS’s considerable resources via our upgraded MACs (Section 5.11), our diversity-focused Communications Plan (Section 5.8), and our experienced and proven training instructors

(Section 5.10.2) to aggressively reach out and encourage new or established Repair Technicians to realize the benefits and opportunities of becoming a Registered Repairer.

Supplemental OBD Training [3.2.1.10.B, 6.10.1.2] 5.10.2

The supplemental OBD training course is a 28-hour training session currently in place and specific to the Massachusetts Program. The current program contractor teaches this course as it is not available through outside training centers or automotive institutes. Upon contract award, SGS

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Technical Response 5-182 April 7, 2016 and our lead trainer (Mr. Chuck Gee) will review the current curriculum with the Agencies to discuss what modifications should be implemented to maximize Program benefit both now and into the future.

The Supplemental OBD Training Course will consist of hands-on training at our MACs by our highly-trained and resident SGS Registered Repairers (hereafter referred to as SGS RRTs). At the MACs, our SGS RRTs maintain up-to-date capability with current Program technology and diagnostic issues. Since our MACs provide free service to motorists looking for assistance to pass failed inspections, each of our SGS RRTs also has the hands-on inspection expertise to provide further inspection-repair insight to prospective Registered Repairers.

The Supplemental OBD Training curriculum will include the following:

Initial Classroom (with Computer) – SGS provides a brief introduction on why the Program exists and how OBD technology is applied to emissions testing. Current OBD trends and issues are discussed, with an emphasis on collecting accurate data from different types of vehicles (e.g., light/medium/heavy duty diesel) and understanding why the quality of that data is important.

Anticipated future trends in OBD technology are presented (particularly for commercial diesel applications) along with resources available online for future reference, study, and information.

Hands-On Workstation Training – Each MAC has a Workstation with OBD DAD that can be operated in training mode to provide an overview of what the Inspector actually does during an inspection. This training mode provides insight into what diagnostic information the inspection is (and isn’t) providing. At the MAC, several types of vehicles are used to show how

OBD data is collected and what problems/issues may affect the inspection process. Both gasoline and diesel vehicle testing is performed and the results displayed and discussed.

Classroom and Hands-On OBD-Driven Emissions Repair Training – Following the above coursework, the student understands what information the Workstation OBD provides during inspection testing. The most common reasons for emissions-related inspection failure are presented, showing students what to expect during the test and how to interpret these results, and what are root causes for these common failures. This course prepares students to answer motorist questions and concerns about “how” the failure occurred and what repairs are necessary to resolve the problem and prepare the vehicle for re-testing.

Certification Exam – A comprehensive examination is given to students and those receiving a passing score are provided a Certificate of Completion and their names are entered into the VID

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Technical Response 5-183 April 7, 2016 for tracking. The student then files a Registered Repairer Application with SGS (through the same methods as described in Section 5.7.1.1) to complete registration.

The course is dynamic and will change throughout the Program duration as OBD capabilities and OBD-driven repair technology changes. SGS is also flexible to provide repair training for specific vehicle types should the Agencies have concerns due to unforeseen manufacturer issues or motorist questions.

Currently, the course is offered quarterly at a cost of $600 per student. SGS’s proposed 28-hour Supplemental OBD Repair Training Course will be offered at 20% less cost ($475 per student), at the same quarterly frequency, and with a minimum enrollment of ten students. Study materials are available (free) for review or download through the Program website to prospective students. We further encourage Repair Technicians to attend this course by offering evening courses for those already working, and informational brochures on this—and all other requirements to become a Registered Repairer—are available at Inspection Stations, repair shops, and the MACs.

Implementing the VMI Training Program [3.2.1.10.C, 6.10.1] 5.10.3

The first step for completing the Registered Repairer process for Repair Technicians with L-1

Certification is to apply online via the Program website that links directly to the SGS classroom management software, Bridge. Similar to how prospective inspectors enroll (Section 5.7. 1.1), Bridge connects to the VID to immediately allow registration and enrollment into desired coursework and track each student’s progress toward becoming a Registered Repairer.

Prospective Registered Repairers are directed to the required training coursework described in

Section 5.10.1, which students must pass before they can complete the registration process.

In addition to the Mass Module and Supplemental OBD Training courses, SGS provides four-hour OBD repair related training courses for Registered Repairers to take annually to maintain their status. We offer these courses quarterly, in the evening, at each of the MACs by SGS’s specialty trainers. SGS will consult with our own SGS RRTs, outside Automotive Industry stakeholders, as well as our internal and external training providers (Messrs. Gee, Protano, Machiros, and Blake in Section 5.10.1) to ascertain what relevant topics should be taught each quarter, based on what is happening in the industry at the time (e.g., analysis of common initial and after-repair diagnostic trouble codes [DTC], controller area network [CAN] bus, and

OBDII). We will review and present the topics to the Agencies for curriculum approval prior to

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Technical Response 5-184 April 7, 2016 each quarter’s class to ensure that the topics are current, in the Agencies’ interest, and informative.

Program Support [3.2.1.10.D, 6.10] 5.10.4

SGS supports the goals of the VMI Program through:

Enhanced registration (Repairers and RRFs)

Improved repair data entry information uploads

Meaningful Emissions Repair Success Rating (ERSR) system

Increased RRF participation through Program advertising

Better database access for Agencies

These points are described in further detail below.

Program Registration 5.10.4.1

SGS will continue to offer Registered Repairer and RRF applicants the ability to apply by mail, online, or by dropping off a completed application at any MAC for maximum accessibility.

We will review the applications for completeness and upload/forward these applications to the

Agencies for review and approval via their Management Console.

We maintain approved Registered Repairers and RRFs on the VID to track certification levels and dates and to associate Registered Repairers with a specific RRF. Both Registered Repairers and RRFs are notified via email at least quarterly of their current status and what certifications will soon expire, including notification when RRFs lose their designated Registered Repairer.

To assist the Agencies and also further our internal Registered Repairer and RRF outreach efforts, SGS makes available through our VID, and therefore through the agencies’ SMART-enabled Management Console, the following information: Number of Registered Repairers (total in Massachusetts and by city and town) and Name of Registered Repairer by Place of Work

(total in Massachusetts and by city and town). RRFs are maintained in the VID for listing on the

Program website and for printing on (failed) inspection VIRs.

Repair Information 5.10.4.2

SGS built and maintains the current Repair Data Entry application on the current

Massachusetts Vehicle Check web page. This application is secure and requires input of

Registered Repairer, RRF, and a personal identification number (PIN) for access and use. We are familiar with the development of this online form and can implement improvements to the form

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Technical Response 5-185 April 7, 2016 as quickly as possible. The easier and more accessible this form is for RRFs, the better chance that useful Program emissions repair information is collected and applied to calculate ERSRs in a meaningful way (Section 5.10.4.4). SGS proposes allowing repair data entry directly from the

Workstation during a retest (an optional feature we could add to the software). For Inspection

Stations that are also RRFs, this would be a more convenient option to increase participation, thus improving the quality of ERSR data.

Calculating Emissions Repair Success Rating (ERSR) 5.10.4.3

RFR Attachment D, Section 14, presents the method to determine repair shop ratings (i.e., ERSR). The ERSR is a rating system, updated quarterly to reflect the past six months’ repair data, which is highly visible to the public through the Program website and other media (e.g., VIR jackets, informative brochures, newsletter). RRFs are rated from five to one stars, as follows:

Five stars – 90-100% retests passed

Four stars – 70-89% retests passed

Three stars – 50-69% retests passed

Two stars – 25-49% retests passed

One star – 1-24% retests passed

N/A – no repairs entered

A “retest passed” occurs when repair data is associated with a passing inspection retest. If the repair data is associated with a failing retest or Not Ready turn-away, then it is a retest failed.

The ratio of retests passed to the total number of retests is then the ERSR Star rating.

Currently, most of the approximately 190 existing RRFs have either Five Star or N/A ratings, with most N/A. Clearly, there are difficulties or lack of incentive with the current method of inputting emissions repairs into the VID and then calculating ERSRs. SGS’s recommendations for updating realistic and accurate ERSRs, resulting in meaningful data for the Agencies, motorists, and the automotive industry itself, are presented next.

Updating ERSRs 5.10.4.4

The data entered (via the website) from the Repair Data Entry application provides the mechanism for tracking repair effectiveness and ERSRs of individual RRFs. The options that

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Technical Response 5-186 April 7, 2016

SGS will discuss with the Agencies to improve ERSR reporting include developing VID triggers that allow more frequent recalculation of ERSR by:

Checking for existing repair data when an emissions re-test comes in, then determining whether the repair was successful based on the test result and recalculating ERSR for that

RRF.

Checking for an existing re-test when we receive repair data, and again recalculating

ERSR.

The ERSR for each RRF would be updated as repair and re-test data provide updated information. ERSRs are available through the VID for website and Agencies’ Management

Console use, and for re-printing on VIRs for those vehicles failing their emission testing. We also will encourage RRF competition by listing ERSR scores – which requires their entering repair data – within the quarterly newsletter distributed to MACs, inspection/repair facilities, and on the Program website.

Method for Selecting Registered Repair Facilities for Printing on VIRs 5.10.4.5

The current SGS VID has geographic information system capability to precisely locate each

RRF and plot its location in any scale on a Commonwealth map. Whenever a vehicle fails an emissions inspection and is issued a (failed) VIR, it comes in a bi-fold jacket that provides helpful information and instructions on what the motorist should do next (Section 5.8.3).

Included in this information is a listing of ten selected RRFs that are highlighted for the motorist to consider for emissions-related repairs, with RRF selection criteria based on (in descending order of importance):

Location. RRFs appearing on printed failing VIRs are limited to those RRFs within thirty road-based miles from the Inspection Station where the failed test occurred, and which perform repairs on the same type of vehicle. RRFs located closest to the subject

Inspection Station are given priority for printing.

ERSR Score. RRFs are prioritized by their ERSR scores, with highest priority given to five star rated RRFs and lowest priority given to one-star and N/A rated RRFs.

Number of ERSR Data. RRFs having a greater number of ERSR data points are assigned a higher priority than those RRFs with fewer ERSR data.

Because the ERSR needs to become a more prominent indicator of RRF quality in the eye of the Public, SGS places considerable importance in encouraging ERSR data inputs by RRFs, and

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Technical Response 5-187 April 7, 2016 will extend a targeted outreach to RRFs, similar to that extended to Registered Repairers and highlighted in Section 5.10.5, to recognize the importance of the ERSR to their business future

(i.e., Newsletter highlights, More prominent web listings).

Agency Access to VMI Information 5.10.4.6

The Agencies have access to all VMI-related information, including ERSR scores (Section

5.10.4.4) and frequently updated listings of Registered Repairers and RRFs (Section 5.10.4.1), through SMART. Beginning with our VMI Plan, and through discussions occurring throughout the Program, SGS will discuss with the Agencies what specific additional data they may need, especially as the VMI changes or is updated.

Registered Repairers and Registered Repair Facilities Growth Strategy [3.2.1.10.E, 5.10.5

6.10.5]

A preliminary approach to defining areas under-represented by RRFs is shown in Figure 5.10-

4. In this figure, the areas between Massachusetts’ western border and the I-91 corridor and the area between the I-91 corridor and the Worcester area have the least density of existing RRFs.

As increased numbers of Registered Repairers is key to increasing the number of RRFs in these areas, so our priority will be to first focus our outreach and encouragement to both of these groups in these areas first. This includes educating the motorist and general public about the importance of RRFs (and thus Registered Repairers) for increasing automotive safety and for improving overall air quality.

Similarly, the benefits available to RRFs over and above “normal” repair facilities are demonstrated through our MACs and Communication Plan, as we aggressively reach out to

RRFs and inform them of the tangible, financial benefits of becoming registered.

SGS will also focus outreach to inform new automotive technicians about ASE A8, A9, and L-

1 certifications as their key to achieving Registered Repairer status. Both early pushing to enlighten prospective technicians and ongoing encouragement to motivate current L-1 certified technicians are essential to meet our goal of increased RRFs via increased Registered Repairers.

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Technical Response 5-188 April 7, 2016

Figure 5.10-4: Locations of MACs and RRFs in Massachusetts. SGS Will Reach Out to Further Develop RRFs in

Under-Represented Areas.

By increasing motorist and general public education about the resources available at the

MACs, the more contact our SGS RRTs will have with interested mechanics and Repair

Technicians. The equipment in the MACs can aid all emissions repairers and SGS will encourage these repairers to come to the MACs and take advantage of the space, equipment, and knowledge there. Our SGS RRTs are an excellent source of assistance to the up and coming repairers and a great sounding board for experienced Registered Repairers to troubleshoot and diagnose new or especially difficult emissions repair-related cases.

We encourage RRFs through prioritized listing of five and four star ERSR businesses on the

Program website and on (failed) VIR printouts. The public wants to know who is best at their profession and, like with all professions, will likely choose the advertised best for their needs.

SGS will approach potential guest lecturers within our Team –and in the automotive industry—to deliver applicable, informative talks to Commonwealth vocational/technical schools to further enlighten prospective students. As described in Section 5.8, we also plan on supplying

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Technical Response 5-189 April 7, 2016 the quarterly newsletter to these same local automotive schools to keep them informed about the opportunities available to them through the Registered Repairer path.

Finally, the SGS Team looks to work closely with the automotive industry stakeholders to help them achieve their own goals. For example, IMPAC is a council that includes associations such as the New England Service Station and Auto Repair Association (NESSARA) and Alliance of

Automotive Service Providers (AASP). These associations provide high-quality automotive repair training at reduced costs to their members, and with their training partners in the

Commonwealth (e.g., ATG), they are a resource that SGS will work with to maximize opportunities for its own members, while at the same time help the Agencies achieve their VMI goals.

5.11 MOTORIST ASSISTANCE CENTERS [3.2.1.11, 6.11]

Using the guidance provided in the RFR, SGS plans to establish ten Motorist Assistance

Centers (MACs) for the Program. The MACs will be easy to locate, provide convenient access and will be in areas that are well lit or otherwise considered safe for the motoring public. We are currently working with a global commercial real estate services company, Cushman &

Wakefield, to identify potential MAC facilities. Figure 5.11-1 illustrates the type and quality of facility that SGS intends to lease for MAC services.

Figure 5.11-1: SGS MAC Building. SGS intends to lease clean, modern, easily located buildings in safe areas that are appealing to motorists and provide all training and testing requirements.

Figure 5.11-2 presents the features of our MAC solution (RFR 6.11) that increase the likelihood of Program success and produce tangible benefits to the Agencies and affected stakeholders.

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Technical Response 5-190 April 7, 2016

Figure 5.11-2: MAC Program Strengths. SGS utilizes the L-1 RRTs for useful tasks.

Strength (Feature of SGS Offer that Increases

Likelihood of Successful Performance or Exceeds

Capability Requirements)

Tangible Benefits to the Agencies, Inspectors, Registered Repair Technicians (RRT), and/or

Motorists

Criteria 1: Overall Management Capability, Accountability, and Experience with Similar Programs

Additional tasking, including covert vehicle preparation and testing, covert visual audits, consumables/parts storage and distribution, and inspection QA/test interrupts, for MAC Automotive Service Excellence

(ASE) L-1 certified RRTs.

Applies the resources of skilled, experienced, but underutilized MAC RRTs to key program functions, resulting in reduced emissions and safer vehicles.

Repair-Related Assistance [3.2.1.11.A, 6.11.3] 5.11.1

Motorists whose vehicles fail inspections seek repairs from registered and non-registered repair shops. The Vehicle Maintenance Initiative (VMI) will add registered repair shops over time to improve the quality of initial repairs and support the Program goal of establishing attractive business opportunities for repair shops through referrals. SGS provides assistance to motorists requesting assistance with repairs by (1) providing Program information and repair referrals to motorists seeking assistance, and (2) providing technical assistance to RRTs working at Registered Repair Facilities (RRF). In Figure 5.11-2, we show the repair-related assistance process flow.

Figure 5.11-2: Repair-Related Assistance Process Flow. Our MAC RRTs provide repair assistance to both motorists and RRF RRTs.

Motorists who fail emissions inspections may call the Motorist Hotline at the Help Desk for assistance. A Customer Service Representative (CSR) provides program information to facilitate their understanding of the activities required to repair and successfully re-inspect the vehicle, as well as the locations of nearby RRFs. If the RRF RRT needs assistance in understanding the

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Technical Response 5-191 April 7, 2016 required repairs, they contact the MAC RRTs who provide assistance to ensure a successful outcome. In many cases we identify solutions over the phone, but if not, the MAC RRT schedules an appointment for the motorist to take the vehicle to a MAC for further diagnosis.

The MAC RRT then contacts the RRF with the information needed to repair the vehicle. The motorist returns to the RRF, gets the necessary repairs, and returns to the original Inspection

Station for a re-inspection.

Emissions Waiver and Hardship Extension Administration [3.2.1.11.B, 6.11.4, 5.11.2

6.11.5]

Emissions waivers are available for authorized motorists who have expended a specified amount of money on eligible repairs in an effort to get their vehicle to pass emissions. The process used to get an emissions waiver includes:

(1) Confirm through examination of receipts that the repairs performed on the vehicle qualify as emissions waiver repairs.

(2) Confirm through examination of the vehicle and receipts that the claimed repairs were performed, that the OBD system has not been subject to unauthorized modification or tampering, and the vehicle has passed its safety inspection.

(3) Verify through the Database that the vehicle does not have Diagnostic Trouble Codes

(DTCs) present that disqualify it from receiving an emissions waiver (e.g., catalytic converter efficiency, misfire) and that it did not receive a hardship extension to complete its previous test cycle.

(4) Verify that related recall and warranty repairs have been completed.

(5) Authorize the issuance of a passing sticker for the vehicle that indicates that it has been waived.

(6) When the vehicle returns to an Inspection Station to receive its waiver and sticker, record the emissions waiver in the Database and update ALARS.

Upon request, SGS makes the detailed information related to emissions waivers (repair receipts) available to the Agencies for auditing. Figure 5.11-3 illustrates our emission waiver process flow.

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Technical Response 5-192 April 7, 2016

Figure 5.11-3: Emission Waiver Process Flow. Emission Waivers are available to motorists who have expended a specified amount on repairs executed by an RRT as verified by the repair receipt and a MAC inspection.

The hardship extension component of the Program provides a passing sticker for vehicles that have met the following criteria:

(1) Repair estimate from a registered emissions repairer exceeds the minimum dollar amount has been submitted

(2) Repair estimate was prepared following the emissions test failure

(3) Repair estimate is appropriate for each DTC, and all DTCs qualify for the hardship extension

(4) OBD system has not been subject to unauthorized modification or tampering

(5) Vehicle has passed the safety test

Figure 5.11-4 depicts the Hardship Extension Process Flow.

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Technical Response 5-193 April 7, 2016

Figure 5.11-4: Hardship Extension Process Flow. Hardship extensions may be granted for emissions repair estimates generated by an RRT that are beyond the capability of the motorist to afford.

Internal Checks to Ensure Waivers Are Properly Issued [3.2.1.11.B.5, 6.11.4] 5.11.2.1

The emissions waiver and hardware extension components of the Program provide a passing sticker for vehicles that have met the following criteria:

(1) Minimum dollar amount has been spent on emissions repairs (for emission waivers), or estimated (for hardship extensions) related to the reason for the emissions test failure (excluding repair costs for tampering, readiness, or failure of the OBD system to communicate)

(2) Repairs were performed (for emission waivers) or estimated (for hardship extensions) following the emissions test failure

(3) Repairs or estimates were performed by a registered emissions repair technician

(4) Vehicle has no DTCs for disqualifying conditions as determined by the Agencies (e.g., catalytic converter efficiency, misfire)

(5) Vehicle initially failed for catalytic converter efficiency, the readiness check now indicates the catalytic converter monitor is Ready

(6) Vehicle has passed the safety test

If any of these conditions are not met, the waiver is denied. The MAC Manager periodically reviews and audits emission waivers, including repair receipts, to be certain they have been issued properly.

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Technical Response 5-194 April 7, 2016

Maintaining Motorist Information [3.2.1.11.B.6, 6.11.4] 5.11.2.2

SGS implements a self-monitoring process for the emissions waiver and hardship extension program to ensure that these waivers are being issued according to the procedures agreed upon by the Agencies. Waiver monitoring data is submitted to the Agencies through the VID. Upon request, we make the detailed information related to emissions waivers (repair receipts) available to the Agencies for auditing.

Readiness Assistance [3.2.1.11.C, 6.11.6] 5.11.3

Emissions system monitors require certain conditions in order to run and allow the vehicle to be ready for inspection. When there is difficulty meeting the conditions through regular driving, the motorist may require assistance to get the vehicle ready for inspection. Readiness assistance requests fall into the following general categories:

A vehicle that is excluded from readiness requirements did not receive its exclusion because vehicle information was not entered correctly into the Workstation. As a result, the test sequence must be reset, the Inspector must be counseled regarding correctly entering identifying information, and the vehicle retested.

The vehicle was serviced or repaired prior to inspection, but the readiness check still indicates the readiness monitors are Not Ready.

The vehicle failed its initial inspection, but the readiness check still indicates the readiness monitors are Not Ready.

The vehicle failed its initial inspection for a catalytic converter efficiency code, but the readiness check still indicates that the catalytic converter monitor is Not Ready (vehicle is turned away if catalytic converter monitor is Not Ready”).

The motorist is unable to operate the vehicle in a way that is likely to allow readiness monitors to become Ready (e.g., motorists who do not operate the vehicle at highway speeds).

Unmet enabling criteria are preventing some or all monitors from becoming Ready.

Power to the power train control module is interrupted when the vehicle is turned off, causing loss of readiness routine memory.

Figure 5.11-5 shows the readiness assistance process flow. On occasion, readiness monitors can be cleared by the motorist. In other cases the vehicle must be referred to a MAC where an

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Technical Response 5-195 April 7, 2016

RRT runs the vehicle on the dynamometer to complete the required drive cycles to set the monitors.

Figure 5.11-5: Readiness Assistance Flow Process. Readiness issues can at times be cleared by the motorist, but often require RRT and dynamometer assistance at the MAC.

SGS applies our extensive experience managing large OBD-based Inspection and Maintenance

(I/M) programs (i.e. California, New Jersey, New York, and Massachusetts) to educate MAC employees and Inspection Stations on readiness issues (e.g. Monitors not Ready) and the methods to get them ready for re-inspection. We use several different delivery methods to present the material and include the concepts of readiness and the enabling criteria, the importance of being “ready” for an OBD inspection, and what to do if a motorist is turned away for an inspection for being “not ready”. This knowledgebase will be incorporated into our

Vehicle Maintenance Initiative (VMI).

As a key means of educating both the motorists and the emissions repairers (RRTs or L-1s), SGS creates and distributes general Program collateral material describing the significance of vehicle OBD readiness, what to do if a vehicle fails emissions, and why it is an important part of the inspection process. We distribute this collateral material to all enrolled Inspection Stations for use by Inspectors and motorists for failed inspections.

The SGS Team responds to motorist inquiries that are received via the Program public web site, email, and the Motorist Hotline. CSRs at the Help Desk enter and track all inquiries into our

HEAT issue tracking system for archiving in the HEAT Database, tracking response times, and

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Technical Response 5-196 April 7, 2016 for reporting. SGS runs HEAT reports on a daily basis and generates lists of all motorist and

MAC inquiries with an open status, including all communications between motorist and RRTs.

The report indicates why each ticket is open (i.e. ticket start time, call details, who is currently working on resolving the issue etc.). Help Desk and MAC staff review open tickets on a daily basis.

The Help Desk CSRs respond to motorist requests via the Hotline for readiness assistance using standard OBD drive cycle information as well as specific drive cycles. CSRs provide assistance to callers during the initial call with predefined questions and call scripts to determine a potential resolution (i.e. have motorist make an appointment to visit the MAC to reset unready monitors to a ready state using a Dyno). For any walk-ins to the MACs, SGS staffs an RRT during MAC normal business hours to answer any questions regarding readiness issues and to assist the motorist with a possible remedy. The MAC has access to Drive Cycle data that can be provided to the motorist upon request.

Targeted Inspections [3.2.1.11.D, 6.11.7] 5.11.4

The goal of the targeted inspections element of the Program is to provide a comprehensive and accurate assessment of vehicles targeted automatically by program software, or manually by the

Agencies, law enforcement, repairers, or other sources, as having a potential emissions or safety problem that warrants further review before the vehicle can receive a passing sticker. Examples include:

Vehicles triggering a potential fraud condition during the emissions or safety inspection

Vehicles identified as having safety or emissions related issues

Vehicles where the OBD VIN and vehicle VIN do not match

Vehicles where the OBD…